FiTAD, Inc. Privacy Policy
FiTAD, Inc. ("FiTAD" or "we", "us", "our") provides services for fitness and health-oriented brands to advertise on mobile devices. This privacy policy (“Privacy Policy") explains how FiTAD strives to collect, use and disclose information that may be personal in nature.
1. DEFINITIONS
The following definitions apply throughout this Policy:
1.1 “Aggregate Information” means data we collect about the characteristics and activities of individuals who receive advertisements through or otherwise interact with FiTAD’s services, are users of FiTAD’s website (the “Site”) or are users of the services of our clients, which does not meet the criteria of Personal Information or from which any Personal Information has been removed. This Privacy Policy in no way limits or restricts our collection, storage, transmission or use of Aggregate Information.
1.2 "FiTAD" means FiTAD Inc., its successors, subsidiaries, divisions and groups.
1.3 "Personal Information" means information that specifically identifies an individual (such as an individual's name, address, telephone number or e-mail address) and information about that individual or such individual’s activities or preferences which would not on its own be considered “Personal Information” but which is directly linked to Personal Information.
1.4 "Sensitive Personal Information" means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns the individual’s health or sex life. FiTAD does not collect Sensitive Personal Information.
1.5 “Service Provider” means a third party company or individual which facilitates FiTAD’s services, provides the services on our behalf, performs related services or assists us in analyzing how our services are used. Service Providers have access to your Personal Information only to perform tasks on our behalf and are obligated not to disclose or use it for any other purpose.
2. GENERAL INFORMATION ABOUT FITAD'S PRIVACY PRACTICES
2.1 FiTAD provides services for fitness and health-oriented brands to advertise on mobile devices. Our services facilitate serving of advertisements within mobile messages (e.g. SMS), the mobile web and within mobile applications by collecting information associated with these services that you visit or use and the advertisements that you see associated with such services. FiTAD may collect and use information when FiTAD or one of our Service Providers places advertisements on a mobile web site or application that you visit or use. We use the information collected by our services in order to help us efficiently deliver those ads and for reporting purposes (e.g., to tell our clients how many ads we delivered in a day.)
2.2 FiTAD does not collect Personal Information directly from individuals but rather receives information via its business partners’ mobile messaging services, mobile web sites and mobile applications as well as from third party service providers (e.g., mobile carrier operators). In this light, FiTAD relies on our business partners and such third party service providers to inform their users about the purposes for which they collect and use Personal Information and may pass that information to us. To the best of our ability we inform our business partners of the need to offer individuals the opportunity to choose (opt-out) whether their Personal Information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
2.3 Consistent with the U.S. Children’s Online Privacy Protection Act of 1998 (COPPA), we will never knowingly collect Personally Information from anyone under the age of thirteen (13) without requiring parental consent.
2.4 When FiTAD receives Personal Information from the entities described above, we will use such information only in accordance with the principles set forth here, the notices such entities provided and the choices made by the individuals to whom such Personal Information relates. When our business partner’s end users connect to the business partner’s service on their mobile device, FiTAD may automatically receive from their mobile phone service provider or our customer partner information identifying the user’s unique mobile device, their phone number and/or other unique identifiers for their device (“Mobile Device Information”).
2.5 FiTAD and/or its Service Providers use “pixel tags" and/or similar technologies in our communications to enable us to evaluate when and if advertisements are viewable on the mobile device. A pixel tag is typically a one-pixel, transparent image (although it can be a visible image as well), located within the advertising creative, which is retrieved from a remote site on the Internet enabling the verification of an individual's viewing or receipt of a Web page or message.
2.6 While FiTAD does not store or maintain Personal Information, we do collect and use Aggregate Information, including: location and service provider information garnered via the IP address used to access the mobile Internet or other means, device identifiers, the type of phone or other mobile device used (e.g., iPhone, Blackberry 8800 etc.), the date and time of a user’s mobile internet session, whether one of the mobile ads we facilitate was delivered and, if applicable, a record if that ad was “clicked.”
2.7 FiTAD collects and retains information passed to us by our business partners and Service Providers as well as records of what application or website owned by our business partners collected the information. For example, we may receive information about an individual’s age, gender and device ID (e.g., Android Advertising ID or Apple Identifier for Advertisers (IDFA)) along with a specific application name e.g., Golfshot. Based on the privacy rules of the application owner and their business agreement with FiTAD or FiTAD’s Service Providers, we may integrate this information with that acquired from other application owners or websites. This information is then used to deliver advertisements and promotional information to the specific device identified based on the individual’s online behavior. If you would like to find out more about behavioral advertising, visit the websites of the Network Advertising Initiative or the Digital Advertising Alliance, where you can also opt-out of behavioral advertising by members of those organizations.
2.8 FiTAD and/or its Service Providers may on occasion receive Personal Information for processing but does not retain that information in an identifiable form. Specifically, FiTAD and/or its Service Providers may receive users’ telephone numbers if the mobile operator facilitates the delivery of those numbers to FiTAD and/or its Service Providers. In those cases, FiTAD may receive the number through the mobile carrier operator. In a similar manner, FiTAD may receive IP addresses of users but does not retain the full set of IP address octets after processing.
2.9 FiTAD uses the collected information to analyze usage trends and patterns that will enable the efficient delivery of optimized advertising placements on behalf of our clients. We also use the information to provide reports and measurement analytics to our clients. We may also aggregate this performance information and share it with FiTAD's affiliates, clients and Service Providers.
3. PRIVACY PRINCIPLES
3.1 NOTICE: When FiTAD collects Personal Information directly from individuals, it will inform them about the purposes for which it collects and uses their Personal Information, the types of non-agent third parties, if any, to which FiTAD discloses that information, and the choices and means, if any, that we offer individuals for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information, or as soon as practicable thereafter, and in any event before FiTAD uses the information for a purpose other than that for which it was originally collected. If FiTAD receives Personal Information from its subsidiaries, affiliates or other entities, it will use such information in accordance with the notices such entities provided and the choices made by the individuals to whom such Personal Information relates.
3.2 CHOICE: FiTAD will offer individuals the opportunity to choose (opt-out) whether their Personal Information is (a) to be disclosed to a non- agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
3.3 DATA INTEGRITY: FiTAD will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. FiTAD will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete and current.
3.4 TRANSFERS TO AGENTS: FiTAD will obtain assurances from its agents that they will safeguard Personal Information consistently with this Privacy Policy. If FiTAD has knowledge that an agent is using or disclosing Personal Information in a manner contrary to this Privacy Policy, FiTAD will take reasonable steps to prevent or stop the use or disclosure.
3.5 ACCESS AND CORRECTION: Upon request, FiTAD will grant individuals reasonable access to Personal Information that it holds about them and FiTAD will take reasonable steps to permit individuals to correct, amend or delete information that is demonstrated to be inaccurate or incomplete.
3.6 SECURITY: FiTAD will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
3.7 ENFORCEMENT: FiTAD will conduct compliance audits of its relevant privacy practices to verify adherence to this Privacy Policy. Any employee that FiTAD determines is in violation of this Privacy Policy will be subject to disciplinary action up to and including termination of employment.
3.8 DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of Personal Information should be directed to the FiTAD at the address given below. FiTAD will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Privacy Policy.
3.9 SERVICE PROVIDERS: We may use Service Providers to help us manage our services and Site and may share usage information with those third party partners. (e.g., web site or database hosting companies, e-mail service providers or analytics companies). We will disclose only that information which is reasonably necessary for our Service Providers to perform the tasks we have assigned.
3.10 AGGREGATE STATISTICS: We may disclose aggregate statistics regarding usage as a measure of interest in, and use of, our services and Site in the form of aggregate data, such as overall patterns or reports that do not describe or identify any individual user.
3.11 COMPELLED DISCLOSURE: We may disclose any information we have to government authorities, and to other third parties when compelled to do so by government authorities or otherwise as required or permitted by law, including but not limited to in response to court orders and subpoenas. We also may disclose information in connection with investigations or when we have reason to believe that someone is causing injury to or interference with our rights or property or users of our services and Site or any other person or business who could be harmed by such activities.
3.12 BUSINESS TRANSFER: FiTAD may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
3.13 CONSENT TO WORLDWIDE TRANSFER AND PROCESSING OF INFORMATION: Information may be processed by FiTAD and/or Service Providers in all countries in which FiTAD, its affiliates and/or its Service Providers operate. Each of these countries has different privacy laws that afford varying levels of protection for information of different types. Regardless of the laws in place in these countries, FiTAD will treat your information in accordance with this Privacy Policy. By providing information to FiTAD or to its Service Providers, you consent to FiTAD’s transmission to, and processing of, your information in any jurisdiction.
3.14 INFORMATION RELATING TO CHILDREN: We do not knowingly collect Personal Information from anyone under the age of 18. If we are made aware that we have received Personal Information from someone under 18, we will use reasonable efforts to remove that information from our records.
3.15 SECURITY: The security of your information is important to us. We have implemented reasonable security measures to protect the information in our care, both during transmission and once we receive it. However, due to the inherent nature of the Internet as an open global communications means, we cannot guarantee that your information, during transmission through the Internet or while stored on our systems, the systems of our Service Providers or otherwise in our care, will be absolutely secure from intrusion by others, such as hackers. If you contact us through the Internet, you should be aware that your transmission might not be secure and that a third party could view information you send by through the Internet in transit. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.
3.16 PASSWORDS: If you are a client of FiTAD’s services and create or are issued a username and password to access or use our services or to access your account, you are responsible for maintaining the strict confidentiality of your password and you shall be responsible for any access to or use of our services or your account by you or any person or entity using your password, whether or not such access or use has been authorized by or on behalf of you and whether or not such person or entity is your employee or agent. YOU ARE RESPONSIBLE FOR MAINTAINING THE SECRECY OF YOUR PASSWORD AT ALL TIMES. You agree to (a) immediately notify FiTAD of any unauthorized use of your password or account or any other breach of security, and (b) ensure that you exit and log out/off from your account at the end of each session. It is your sole responsibility to protect your password, control access to and use of your account, and notify FiTAD when you desire to cancel your account. We will not be responsible or liable for any loss or damage arising from your failure to comply with this provision.
4. CONTACT INFORMATION
Questions or comments regarding this Privacy Policy should be submitted to FiTAD by mail or email as follows:
Privacy Matters
FiTAD, Inc.
151 East 31st Street
23rd Floor
New York, NY 10016
United States
Email: GO@FiTAD.com
5. CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may be amended from time to time. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the Personal Information we collect. Use of FiTAD’s services and/or Site constitutes your agreement to this Privacy Policy and any updates.
Last updated September 25, 2015
FiTAD, Inc. ("FiTAD" or "we", "us", "our") provides services for fitness and health-oriented brands to advertise on mobile devices. This privacy policy (“Privacy Policy") explains how FiTAD strives to collect, use and disclose information that may be personal in nature.
1. DEFINITIONS
The following definitions apply throughout this Policy:
1.1 “Aggregate Information” means data we collect about the characteristics and activities of individuals who receive advertisements through or otherwise interact with FiTAD’s services, are users of FiTAD’s website (the “Site”) or are users of the services of our clients, which does not meet the criteria of Personal Information or from which any Personal Information has been removed. This Privacy Policy in no way limits or restricts our collection, storage, transmission or use of Aggregate Information.
1.2 "FiTAD" means FiTAD Inc., its successors, subsidiaries, divisions and groups.
1.3 "Personal Information" means information that specifically identifies an individual (such as an individual's name, address, telephone number or e-mail address) and information about that individual or such individual’s activities or preferences which would not on its own be considered “Personal Information” but which is directly linked to Personal Information.
1.4 "Sensitive Personal Information" means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns the individual’s health or sex life. FiTAD does not collect Sensitive Personal Information.
1.5 “Service Provider” means a third party company or individual which facilitates FiTAD’s services, provides the services on our behalf, performs related services or assists us in analyzing how our services are used. Service Providers have access to your Personal Information only to perform tasks on our behalf and are obligated not to disclose or use it for any other purpose.
2. GENERAL INFORMATION ABOUT FITAD'S PRIVACY PRACTICES
2.1 FiTAD provides services for fitness and health-oriented brands to advertise on mobile devices. Our services facilitate serving of advertisements within mobile messages (e.g. SMS), the mobile web and within mobile applications by collecting information associated with these services that you visit or use and the advertisements that you see associated with such services. FiTAD may collect and use information when FiTAD or one of our Service Providers places advertisements on a mobile web site or application that you visit or use. We use the information collected by our services in order to help us efficiently deliver those ads and for reporting purposes (e.g., to tell our clients how many ads we delivered in a day.)
2.2 FiTAD does not collect Personal Information directly from individuals but rather receives information via its business partners’ mobile messaging services, mobile web sites and mobile applications as well as from third party service providers (e.g., mobile carrier operators). In this light, FiTAD relies on our business partners and such third party service providers to inform their users about the purposes for which they collect and use Personal Information and may pass that information to us. To the best of our ability we inform our business partners of the need to offer individuals the opportunity to choose (opt-out) whether their Personal Information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
2.3 Consistent with the U.S. Children’s Online Privacy Protection Act of 1998 (COPPA), we will never knowingly collect Personally Information from anyone under the age of thirteen (13) without requiring parental consent.
2.4 When FiTAD receives Personal Information from the entities described above, we will use such information only in accordance with the principles set forth here, the notices such entities provided and the choices made by the individuals to whom such Personal Information relates. When our business partner’s end users connect to the business partner’s service on their mobile device, FiTAD may automatically receive from their mobile phone service provider or our customer partner information identifying the user’s unique mobile device, their phone number and/or other unique identifiers for their device (“Mobile Device Information”).
2.5 FiTAD and/or its Service Providers use “pixel tags" and/or similar technologies in our communications to enable us to evaluate when and if advertisements are viewable on the mobile device. A pixel tag is typically a one-pixel, transparent image (although it can be a visible image as well), located within the advertising creative, which is retrieved from a remote site on the Internet enabling the verification of an individual's viewing or receipt of a Web page or message.
2.6 While FiTAD does not store or maintain Personal Information, we do collect and use Aggregate Information, including: location and service provider information garnered via the IP address used to access the mobile Internet or other means, device identifiers, the type of phone or other mobile device used (e.g., iPhone, Blackberry 8800 etc.), the date and time of a user’s mobile internet session, whether one of the mobile ads we facilitate was delivered and, if applicable, a record if that ad was “clicked.”
2.7 FiTAD collects and retains information passed to us by our business partners and Service Providers as well as records of what application or website owned by our business partners collected the information. For example, we may receive information about an individual’s age, gender and device ID (e.g., Android Advertising ID or Apple Identifier for Advertisers (IDFA)) along with a specific application name e.g., Golfshot. Based on the privacy rules of the application owner and their business agreement with FiTAD or FiTAD’s Service Providers, we may integrate this information with that acquired from other application owners or websites. This information is then used to deliver advertisements and promotional information to the specific device identified based on the individual’s online behavior. If you would like to find out more about behavioral advertising, visit the websites of the Network Advertising Initiative or the Digital Advertising Alliance, where you can also opt-out of behavioral advertising by members of those organizations.
2.8 FiTAD and/or its Service Providers may on occasion receive Personal Information for processing but does not retain that information in an identifiable form. Specifically, FiTAD and/or its Service Providers may receive users’ telephone numbers if the mobile operator facilitates the delivery of those numbers to FiTAD and/or its Service Providers. In those cases, FiTAD may receive the number through the mobile carrier operator. In a similar manner, FiTAD may receive IP addresses of users but does not retain the full set of IP address octets after processing.
2.9 FiTAD uses the collected information to analyze usage trends and patterns that will enable the efficient delivery of optimized advertising placements on behalf of our clients. We also use the information to provide reports and measurement analytics to our clients. We may also aggregate this performance information and share it with FiTAD's affiliates, clients and Service Providers.
3. PRIVACY PRINCIPLES
3.1 NOTICE: When FiTAD collects Personal Information directly from individuals, it will inform them about the purposes for which it collects and uses their Personal Information, the types of non-agent third parties, if any, to which FiTAD discloses that information, and the choices and means, if any, that we offer individuals for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information, or as soon as practicable thereafter, and in any event before FiTAD uses the information for a purpose other than that for which it was originally collected. If FiTAD receives Personal Information from its subsidiaries, affiliates or other entities, it will use such information in accordance with the notices such entities provided and the choices made by the individuals to whom such Personal Information relates.
3.2 CHOICE: FiTAD will offer individuals the opportunity to choose (opt-out) whether their Personal Information is (a) to be disclosed to a non- agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
3.3 DATA INTEGRITY: FiTAD will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. FiTAD will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete and current.
3.4 TRANSFERS TO AGENTS: FiTAD will obtain assurances from its agents that they will safeguard Personal Information consistently with this Privacy Policy. If FiTAD has knowledge that an agent is using or disclosing Personal Information in a manner contrary to this Privacy Policy, FiTAD will take reasonable steps to prevent or stop the use or disclosure.
3.5 ACCESS AND CORRECTION: Upon request, FiTAD will grant individuals reasonable access to Personal Information that it holds about them and FiTAD will take reasonable steps to permit individuals to correct, amend or delete information that is demonstrated to be inaccurate or incomplete.
3.6 SECURITY: FiTAD will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
3.7 ENFORCEMENT: FiTAD will conduct compliance audits of its relevant privacy practices to verify adherence to this Privacy Policy. Any employee that FiTAD determines is in violation of this Privacy Policy will be subject to disciplinary action up to and including termination of employment.
3.8 DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of Personal Information should be directed to the FiTAD at the address given below. FiTAD will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Privacy Policy.
3.9 SERVICE PROVIDERS: We may use Service Providers to help us manage our services and Site and may share usage information with those third party partners. (e.g., web site or database hosting companies, e-mail service providers or analytics companies). We will disclose only that information which is reasonably necessary for our Service Providers to perform the tasks we have assigned.
3.10 AGGREGATE STATISTICS: We may disclose aggregate statistics regarding usage as a measure of interest in, and use of, our services and Site in the form of aggregate data, such as overall patterns or reports that do not describe or identify any individual user.
3.11 COMPELLED DISCLOSURE: We may disclose any information we have to government authorities, and to other third parties when compelled to do so by government authorities or otherwise as required or permitted by law, including but not limited to in response to court orders and subpoenas. We also may disclose information in connection with investigations or when we have reason to believe that someone is causing injury to or interference with our rights or property or users of our services and Site or any other person or business who could be harmed by such activities.
3.12 BUSINESS TRANSFER: FiTAD may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
3.13 CONSENT TO WORLDWIDE TRANSFER AND PROCESSING OF INFORMATION: Information may be processed by FiTAD and/or Service Providers in all countries in which FiTAD, its affiliates and/or its Service Providers operate. Each of these countries has different privacy laws that afford varying levels of protection for information of different types. Regardless of the laws in place in these countries, FiTAD will treat your information in accordance with this Privacy Policy. By providing information to FiTAD or to its Service Providers, you consent to FiTAD’s transmission to, and processing of, your information in any jurisdiction.
3.14 INFORMATION RELATING TO CHILDREN: We do not knowingly collect Personal Information from anyone under the age of 18. If we are made aware that we have received Personal Information from someone under 18, we will use reasonable efforts to remove that information from our records.
3.15 SECURITY: The security of your information is important to us. We have implemented reasonable security measures to protect the information in our care, both during transmission and once we receive it. However, due to the inherent nature of the Internet as an open global communications means, we cannot guarantee that your information, during transmission through the Internet or while stored on our systems, the systems of our Service Providers or otherwise in our care, will be absolutely secure from intrusion by others, such as hackers. If you contact us through the Internet, you should be aware that your transmission might not be secure and that a third party could view information you send by through the Internet in transit. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.
3.16 PASSWORDS: If you are a client of FiTAD’s services and create or are issued a username and password to access or use our services or to access your account, you are responsible for maintaining the strict confidentiality of your password and you shall be responsible for any access to or use of our services or your account by you or any person or entity using your password, whether or not such access or use has been authorized by or on behalf of you and whether or not such person or entity is your employee or agent. YOU ARE RESPONSIBLE FOR MAINTAINING THE SECRECY OF YOUR PASSWORD AT ALL TIMES. You agree to (a) immediately notify FiTAD of any unauthorized use of your password or account or any other breach of security, and (b) ensure that you exit and log out/off from your account at the end of each session. It is your sole responsibility to protect your password, control access to and use of your account, and notify FiTAD when you desire to cancel your account. We will not be responsible or liable for any loss or damage arising from your failure to comply with this provision.
4. CONTACT INFORMATION
Questions or comments regarding this Privacy Policy should be submitted to FiTAD by mail or email as follows:
Privacy Matters
FiTAD, Inc.
151 East 31st Street
23rd Floor
New York, NY 10016
United States
Email: GO@FiTAD.com
5. CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may be amended from time to time. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the Personal Information we collect. Use of FiTAD’s services and/or Site constitutes your agreement to this Privacy Policy and any updates.
Last updated September 25, 2015
